April 10, 2006

AGA Chemicals America, Inc.

Asahi Glass Co., Ltd.

Answers to EPA’s inquiries in Ms. Margaret Sheppar’s e-mail to Mr.
David Ferguson dated March 1, 2006 concerning SNAP application of
Asahiklin AE-3000

Additional toxicity studies data: please refer to attached revised Table
2.

Flash point data: please refer to attached Analysis Report (Attachment
1) prepared by Sumika Chemical Analysis Services Ltd. We also carried
out the test by Cleveland Open Cup tester ASTM D92-05a. The substance
also has no flash point.

Flammability limits: tests were carried out by ASTM E681-01 method. We
could not find any flammability for any mixtures of the substance and
air. I addition, flammable solvent HFC-365mfc (CF3CH2CF2CH3) which has
flammability limit 5-9vol% in air becomes nonflammable with adding only
1.5vol% of the substance, AE-3000. The experimental data (Attachment 2)
is attached. In the figure, circle (O) means flammable and x means
nonflammable.

Ozone depletion potential: the substance does not contain any bromine
and chlorine atoms in the molecule. So, it has no ozone depletion
potential.

Global warming potential: the GWP value was calculated based on the test
results by Research Institute of Innovative Technology for the Earth in
Japan. Unfortunately, the paper is written in Japanese and a report
describes such calculation in English is not published. But the GWP
value is shown in the report “Safeguarding the Ozone Layer and the
Global Climate System” published by the Intergovernmental Panel on
Climate Change in 2005. Please refer to attached copy of the report
(Attachment 3). The value is 540 (100yrs ITH) in the report.

Atmospheric lifetime: please refer to attached copy of J. Phys. Chem. A
2000, 104, 1165-1170 (Attachment 4).

Protective equipment: respiratory protection for organic chemicals
approved by NIOSH is recommended. In case of very high concentration,
self-contained breathing apparatus is recommended. To protect hand and
eye, impermeable gloves and chemical splash goggles are recommended,
respectively. Local exhaust should be used if large amount of the
substance are released. Mechanical ventilation should be used in low
places.

Degradation products: this substance may be decomposed by high
temperature (open flames, glowing metal surfaces, electrical heating
elements and so on) forming hydrofluoric acids, carbonyl fluoride,
carbon monoxide and carbon dioxide. 

Regulation under environmental regulatory statutes other than VOC: none.

Regulation under health and safety related statutes authorities: we have
submitted PNM of TSCA and waiting the approval from US EPA. No
regulations are made by FDA, OSHA, DOT and so on.

Manufacture site: Japan. We do not have any plan to manufacture this
substance in the US right now.

Material Safety Data Sheet: please refer to attached copy.

